Residential risks and responsibilities: Are you ready for the new RPEEPs regulations?
Iain Hoey
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With RPEEPs coming into force in England this month, residential evacuation planning is shifting from building-level assumptions to resident-level assessment, decision-making and record keeping
From 6 April 2026, responsible persons in England will be under a new statutory duty to identify residents in certain residential buildings whose ability to evacuate without assistance is compromised, offer them a person-centred fire risk assessment and, where an approach is agreed, record that in writing.
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 place individual evacuation planning on a statutory footing for the first time.
They bring high-rise buildings and some mid-rise buildings with simultaneous evacuation strategies into scope.
They also respond directly to recommendations made after the Grenfell Tower fire.
What changes is the point at which decisions are made.
Evacuation planning is now carried out at resident level, with decisions recorded through residential personal emergency evacuation plans (RPEEPs).
From evacuation strategy to individual risk
The regulations require a shift in how risk is understood.
Stay put and simultaneous evacuation strategies remain in place, while evacuation planning also addresses how residents who need assistance will move if conditions change.
During a webinar called ‘RPEEPs: One month to go!’, Elspeth Grant, CEO of Triple A Solutions pointed out that this is less a niche issue than an operational reality: “For these in-scope buildings it would be highly unlikely to have any building that has nobody evacuation impaired.”
That matters because building strategies do not remove the need for individual planning.
Drawing on her experience, Grant said even in stay put buildings, the key question is what happens if a resident cannot remain safely in their flat, noting that the expectation is to “move away” rather than remain in place.
Her framing brings the regulations into practical focus.
The requirement centres on how a named resident would move if conditions inside their flat changed.
Core duties and ongoing process
The regulations apply to buildings in England that meet defined height or storey thresholds, or operate a simultaneous evacuation strategy.
Within those buildings, responsible persons must use reasonable endeavours to identify residents whose ability to evacuate without assistance is compromised by a physical or cognitive condition.
Once identified, the process moves into engagement.
A person-centred fire risk assessment must be offered and carried out if the resident agrees.
The responsible person must then consider what measures are reasonable and proportionate, attempt to agree an evacuation approach and record that approach where agreement is reached.
This is an ongoing process.
Residents move in and out of buildings, health conditions change and some individuals will only come forward after initial contact.
The duty remains active, which means systems need to stay current.
Identification challenges in practice
On paper, identifying relevant residents appears straightforward.
In practice, it is one of the more complex parts of compliance.
Guidance suggests identification at move-in, alongside regular reminders.
That relies on residents engaging with the process and disclosing information.
Some will not respond.
Others may not recognise that their condition affects evacuation.
In larger buildings, maintaining accurate records becomes a continuous task.
Grant’s view is that the starting point should be existing data, advising responsible persons to begin with “what information you already have within your systems.”
That reflects what was already known before Grenfell.
She pointed out that building managers were “already fully aware” of many residents’ needs through existing records, including lease information.
Identification therefore includes using current data alongside internal reporting routes.
Grant described this as “network fire safety,” where contractors and others on site can raise concerns as they arise.
Consent and information sharing
The regulations require explicit consent before prescribed information about a resident is shared with the local fire and rescue authority.
This introduces a clear procedural step and sits alongside wider legislation on emergency response and data use.
Grant explained that RPEEPs sit within a wider legal framework, including the Fire Safety Order and the Equality Act, alongside what she described as the “consent minefield” of data legislation.
She added that in emergency or safeguarding situations, the Data Use and Access Act can remove the need for consent.
Consent requirements within the regulations remain in place.
Emergency response may be governed by a different legal threshold.
For responsible persons, the task is to manage both.
Consent must be handled carefully within the RPEEPs framework, while recognising how emergency provisions apply.
Handling sensitive resident data
Even where information sharing is lawful, storing and managing resident data introduces its own risk.
The information recorded may indicate where vulnerable residents live and what assistance they may require.
Guidance supports digital storage because it allows updates to be made more easily.
Some fire and rescue authorities may still require physical information boxes on site, which creates variation between local areas.
Grant’s warning on this point is direct: Information should not be stored in a way that exposes residents, and instead should be “coded” to reduce risk if accessed by the wrong people.
The regulations require compliance with data protection law.
Responsible persons need to develop systems that reduce exposure while keeping information accurate.
Cost and legal exposure
The regulations allow mitigating measures to be funded in different ways, depending on circumstances and lease arrangements.
This flexibility creates uncertainty when it intersects with duties under the Equality Act.
Grant highlighted the constraint clearly: “The Equality Act specifically prohibits the charging of a disabled person for a reasonable adjustment.”
This limits how costs can be allocated in practice.
A measure identified through a RPEEPs process may still fall within the definition of a reasonable adjustment, which affects who can be asked to pay for it.
Alongside cost sits personal liability.
Duties under the Fire Safety Order apply to individuals as well as organisations.
Decisions made during the RPEEPs process may later be examined in enforcement or legal proceedings.
Delivering and evidencing the process
Government estimates suggest around a quarter of residents in high-rise buildings may be evacuation impaired, which places ongoing demands on identification, assessment and review.
Records need to remain current as residents move and circumstances change, requiring a system that reflects the building as it is, not as it was.
The regulations do not require specialist consultants, and the resident-facing work is expected to sit with building staff.
Grant drew a distinction between strategy and delivery: “A consultant might be able to help you develop a strategy,” but added that it would be “counterproductive” for unfamiliar assessors to carry out person-centred conversations.
She also pointed to a core principle in guidance, that evacuation planning should enable residents to leave without relying on rescue services.
Compliance will be judged on evidence.
Responsible persons need to show how residents are identified, how decisions are made and how records are maintained.
As Grant put it, the test is whether you can prove what is “reasonable.”
Conclusion
RPEEPs introduce a clear expectation that evacuation planning must account for individual residents.
The regulations define what responsible persons need to do, while leaving key questions to be worked through in practice.
The shift to resident-level planning brings practical challenges.
Identification is continuous. Data handling requires care.
Decisions on measures may carry legal implications.
The purpose remains straightforward: Residents who cannot evacuate independently should be identified and supported through a recorded plan.
The difficulty lies in delivering that requirement across changing populations, with systems that stand up to scrutiny and reflect real conditions inside each building.
